must my warranty period be stated in the digital product passport

What you concretely must do

What is expected of you

The ESPR itself does not explicitly prescribe that a warranty period must be included in the digital product passport. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what types of information a product passport can contain and how they must be presented technically, but the precise content for a product group such as mattresses is only determined in the product-specific delegated act. What warranty information is actually mandatory for mattresses is therefore not yet established. There is, however, a clear line to be drawn from Articles 5 to 7 of the ESPR, which deal with ecodesign, performance and information requirements: warranty is closely related to expected lifetime, and that is a subject to which the ESPR attaches considerable weight.

Being able to provide warranty period correctly, should it become mandatory

For a company with 10 to 100 employees, this above all means: ensure that the warranty period you currently use is clearly and unambiguously defined per model. Not "typically 5 years, unless otherwise stated on the website", but a concrete data point per product code. If the delegated act subsequently designates warranty period as a mandatory field, that data must be retrievable from your systems without difficulty.

Making a distinction between warranty and durability claim

Warranty is a contractual undertaking; expected lifetime is a technical assessment. They are often confused with each other, even internally. A supplier that puts "10 years warranty" on the packaging is not automatically considered to be able to substantiate a lifetime of 10 years to the passport. If you want to prepare now for what will definitely come, you can look at how the expected lifetime of a mattress is substantiated — that is a different data point than the warranty period, but in practice it is often lumped together by purchasers and customers.

Ensuring consistency between warranty conditions and passport data

Even if the warranty period is not designated as a separate passport field, a business runs the risk that warranty conditions contradict what is stated in the passport about composition, foam type or maintenance. A warranty that lapses due to "misuse" must align with the maintenance and use information already established elsewhere, for example in the way foam type and density are documented. Discrepancies between warranty documents and passport data are an obvious point of attention in a later inspection.

Where things go wrong in practice

A few situations come up regularly in practice.

First: warranty periods that differ per sales channel. The web shop promises something different from the physical store, and the export market something different again. Once warranty information must be linked to a product passport that is requested per mattress and not per channel, it becomes clear that there is no single answer.

Second: warranty presented as a quality mark, while the underlying technical substantiation is lacking. A marketing text mentions "20 years warranty on the core", but no one in the company can explain on the basis of which test or standard that figure was chosen. Once a passport asks for substantiation instead of a claim, this falls through.

Third: warranty conditions that refer to maintenance instructions that no longer exist or have not been updated since a material change. A mattress with a new foam composition sometimes accidentally receives the old warranty text, while the properties — and with them the assumptions behind the warranty — have changed.

Fourth: confusion between legal conformity (which is separate from the ESPR) and the voluntary commercial warranty that a manufacturer undertakes. Both are often placed in one paragraph on the packaging, making it difficult to point out exactly which data is meant at a passport field.

Fifth: businesses that treat warranty information as commercially sensitive and therefore prefer not to record anything rather than create uncertainty about what should and should not be public. This overlaps with the broader question whether business-sensitive data about mattresses must be made public — a question that has little to do with warranty periods as such, but is often linked to them in decision-making.

What you can record

• An overview per product model of the exactly applicable warranty period, including any exceptions (for example a different period for the ticking versus the core).
• The warranty conditions in their current, up-to-date version, dated and linked to the product code for which they apply.
• A brief note on the relationship between warranty period and expected service life: are these the same figures, or deliberately different, and why.
• A check that the warranty text matches the maintenance instructions already recorded elsewhere, in particular regarding what users may and may not do themselves without losing the warranty.
• A note on how often warranty conditions are reviewed and by whom, so that there is a record if this information needs to be updated later — something that relates to the broader question how current the data in the product passport must be.
• Once the product-specific delegated act for mattresses is published: a comparison between what is designated as a mandatory passport field and what the company currently has in warranty information, in order to flag differences in time.

This page will be updated once the delegated act for mattresses is known and it becomes clear whether warranty period is actually designated as a mandatory passport field.